Summary of Adamson v. California
Citation: 332 U.S. 46
Relevant Facts: Adamson was tried for first degree murder and ultimately convicted of the crime. Although defendants have the right to not self-incriminate as prescribed by the Fifth Amendment, the prosecuting attorney made disparaging comments about the defendant’s decision not to testify on his own behalf.
Issues: The legal issue presented was whether the Fifth Amendment’s right against self-incrimination applies in state courts, and is protected by the Due Process Clause of the Fourteenth Amendment.
Holding: The Supreme Court held that in Adamson’s case, his rights had not been violated, because the Bill of Rights protection against self-incrimination did not automatically apply to the states.
Reasoning: The Supreme Court reasoned that the Fourteenth Amendment’s Due Process Clause did not extend to a defendant’s right to not bear witness against himself as promised in the Fifth Amendment. The Court cited Twining v. New Jersey and Palko v. Connecticut as precedents of this rationale. Justice Reed, in particular, asserted that the Fourteenth Amendment did not automatically apply to all federal immunities and privileges being awarded at the state level.
Dissent: Justice Black vehemently disagreed with the majority ruling in his dissent, and argued that for the Bill of Rights to be meaningful in the manners in which most people have need to use the protections, it must be absolute and apply to state matters.
Conclusion: This case was important more so because of its dissenting opinion, which would ultimately become case law in a number of rulings handed down by the Warren Court in a number of civil liberties affirming decisions.